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Online Courses and Ordinance H-18 (2025): Cash Receipts

Online Courses and Ordinance H-18 (2025): Cash Receipts

Online courses and Ordinance H-18 (2025): when a cash receipt is issued and what the exceptions are for electronic payments.

Approximate reading time: 3m 38s

Selling online courses is one of the fastest-growing sectors in e-commerce. However, many entrepreneurs and training centers ask: do we need to issue cash receipts for payments?

This question becomes especially relevant after the latest changes to Ordinance No. H-18/2006, published in State Gazette, issue 42 of May 23, 2025

In this article, we will look at the essence of the changes, what they affect in online stores, and most importantly – what this means for those who sell online courses.

 

What is Ordinance H-18?

Ordinance No. H-18 of the Ministry of Finance, adopted in 2006, is a regulatory act that governs:

  • the registration and reporting of sales in retail outlets;

  • the use of fiscal devices (cash registers, fiscal printers, electronic systems with fiscal memory);

  • the remote connection of these devices to the NRA;

  • sales management software (SUTO).

The main goal is to ensure transparency and control over turnover and prevent revenue concealment.

What changed in 2025?

In 2025, the Ministry of Finance introduced amendments that strengthen control over the way data from fiscal devices and SUTO are transmitted to the NRA.

The main highlights are:

  • mandatory remote real-time connection between the devices and the NRA;

  • deadlines of 3 to 6 months for manufacturers and importers to bring their devices into compliance;

  • new technical requirements for SUTO;

  • clarifications in terminology in the annexes to the ordinance.

These changes mainly affect traders who sell tangible goods and accept payments in cash or by cash on delivery.

Where do online courses fit in?

Selling online courses is a special case:

  • the product is intangible (video lessons, digital materials, webinars);

  • delivery is entirely online;

  • payments are most often made by bank transfer or via a virtual POS terminal.

This places online courses outside the scope of mandatory issuance of cash receipts for electronic payments.

What does the ordinance say?

In the latest amendments to Ordinance H-18, a new para. 19 to Art. 3 was added, according to which:

„The fiscal and system receipt may be issued electronically without being printed on paper when issued by an ESFP or IASUTD.“

This is the official text related to electronic receipts.

At the same time, the NRA also gives clear guidance that:

  • An online store that accepts payments solely by bank transfer (including card payments via virtual POS or PayPal) does not fall within the scope of Art. 3 of the Ordinance and has no obligation to issue cash receipts.

This is exactly the exception that applies to online courses.

When is a cash register needed?

Despite the exception, there are situations in which it is required:

  • if a client pays in cash at your office;

  • if you also sell physical products together with the courses;

  • if you organize in-person training with on-site payments.

What remains mandatory?

Even if you do not issue cash receipts, you have other obligations:

  • issuing an invoice upon request;

  • accounting treatment – every payment is visible in the bank statement;

  • compliance with tax legislation – VAT and corporate tax according to turnover;

  • GDPR compliance when processing learners' personal data.

Practical tips

  1. Accept payments only by bank or online – avoid cash payments.

  2. Offer electronic invoices.

  3. Inform your clients on your website – for example with a note: „We do not issue cash receipts because payments are made by bank transfer, in accordance with Ordinance H-18“.

  4. Monitor the NRA website for up-to-date guidance.

  5. Work with an accountant.

Frequently asked questions

If I sell a course and a book at the same time?
The rules for goods apply to the book. If the payment is in cash or cash on delivery, a cash register is needed.

If a client comes to the office and pays in cash?
Issuing a cash receipt is mandatory.

Do I have to issue receipts for payments with PayPal or Stripe?
No – these are licensed payment providers that fall under the exception.

If I offer a subscription for courses?
If the payment is received by bank or card – no cash receipt is required.

And for international payments?
The same rule applies – if it is through a bank or payment system, there is no cash receipt. However, you need to follow VAT rules for sales in the EU.

Conclusion

When you sell online courses, the question often arises whether a cash receipt should be issued for an online course and whether a cash register is needed for online courses.

According to Ordinance H-18 2025, there are a number of exceptions in which an online store does not issue cash receipts, especially when the payment is made by bank transfer or through a card system.

That is why it is important to know the current NRA requirements for online stores in 2025 in order to avoid sanctions. Many platform owners ask what changes in Ordinance H-18 for online training and what their obligations are for issuing invoices for online courses.

The answer is clear – if the payment is electronic, there is no need to issue a fiscal receipt from the online store Ordinance H-18, and an invoice is sufficient.

Still, when payment is made in cash, including for online training, the rules change and a recorded fiscal receipt online store must be issued through SUTO online commerce.

This way you will know exactly when an online store does not issue cash receipts and when a cash register is needed for online courses.

 

In 2025, Ordinance H-18 was updated, but the exception for online stores that accept payments only by bank or through online systems remains.

For online courses, this means that you do not need to issue cash receipts, as long as payments are not made in cash. Your commitments are:

  • issuing invoices upon request;

  • proper accounting treatment;

  • compliance with tax and GDPR legislation.

This way you can calmly grow your business with online training, without investing in cash registers and SUTO, if you work exclusively with electronic payments.

Always consult a lawyer or your accountant! The article is informational, reflects current changes, and does not constitute legal advice. 

Често задавани въпроси

Do I need to issue a cash receipt when selling online courses?
Usually no, if your online courses are paid only by bank transfer or through electronic payment systems such as a virtual POS, PayPal, or Stripe. The article states that this type of business falls outside the scope of the cash receipt obligation for electronic payments. In that case, an invoice is sufficient when needed, and the payment is recorded through your bank statement.
When is a cash register required for online courses?
A cash register becomes necessary if you accept cash payments. This includes situations where a client pays at your office, where you sell physical products together with the course, or where you hold in-person training with on-site payment. In those cases, the rules for cash receipts apply, even if your main business is online courses.
Are card payments and PayPal subject to cash receipt rules?
No. Payments made by bank transfer, card through a virtual POS, PayPal, and similar licensed payment providers are treated as electronic payments. For these payments, the article says there is no obligation to issue a cash receipt. An invoice may still be issued upon request, but a fiscal receipt is not required for the online transaction.
What changed in Ordinance H-18 in 2025?
The 2025 amendments strengthened control over the transmission of data from fiscal devices and sales software to the NRA. The main changes include mandatory remote real-time connection, deadlines for manufacturers and importers to comply, new technical requirements for sales management software, and clarifications in the annexes. These changes mainly affect traders handling cash or cash-on-delivery sales.
Do online courses fall under the same rules as physical goods?
No. Online courses are treated as a special case because the product is intangible and delivery is entirely online. The article explains that this places them outside the scope of mandatory cash receipt issuance for electronic payments. Physical goods, however, are treated differently, especially if they are paid for in cash or cash on delivery.
What other obligations do I have if I do not issue cash receipts?
Even without cash receipts, you still need to comply with other legal duties. These include issuing an invoice upon request, keeping proper accounting records, following VAT and corporate tax rules, and protecting learners' personal data under GDPR. The article also recommends checking current NRA guidance and working with an accountant.